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Edited version of your written advice
Authorisation Number: 1012756007882
Ruling
Subject: CGT cost base
Question and Answer
Do you calculate the cost base of your assets from the day you cease to be a temporary resident but remain an Australian resident?
Yes
This ruling applies for the following period(s)
Year ended 30 June 2014
The scheme commences on
1 July 2010
Relevant facts and circumstances
You arrived in Australia on a temporary resident visa during the financial year ended 30 June 2011
You became a permanent resident on during the financial year ended 30 June 2014.
You own CGT assets outside of Australia.
Relevant legislative provisions
Section 768-955 of the Income Tax Assessment Act 1997
Reasons for decision
Temporary residents and CGT
Normally, when a foreign resident becomes an Australian resident, a cost base applies for certain assets held by that person. This rule will not apply where the person is a temporary resident.
Where a temporary resident ceases to be a temporary resident but remains an Australian resident (e.g. becomes a permanent resident), the first element of the cost base or reduced cost base of each CGT asset that is brought within the CGT net as a result of your change of residency status. The cost base is deemed to be the asset market value at the time you ceased to be a temporary resident. The CGT provisions will apply to the asset as if it had been acquired at that time.
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